The OSHA Bloodborne Pathogens Standard (BPS) requires employers to get workers' input regarding safe devices to cut the risk of injuries from contaminated sharps. You also need to document that input. One effective strategy to ensure compliance is "pilot testing," that is, letting workers test the device and fill out a questionnaire to evaluate its effectiveness. We'll show you how to implement this strategy. There's also a model questionnaire in Tools that you can access if you're a SafetyXChange member.

The OSHA Standard

The BPS says employers must consider adopting as "engineering controls" safe medical devices, such as sharps with engineered sharps industry protections and needleless systems.  Employers are supposed to evaluate new safety devices as they come on the market and figure out if they're effective and easy to use. Under Sec. 1910.1030(c)(1)(v), employers must also get workers' input in identifying, evaluating and selecting these devices and document the methods used to get such input in their Exposure Control Plan (ECP).

Pilot Testing

Pilot testing is one of the methods you can use to meet the BPS requirements. This generally involves ordering a small number of devices and letting workers test them on fellow workers posing as patients in simulated patient encounters. When testing ends, workers should fill out a questionnaire evaluating the device, the effectiveness of its safety features and physical configuration, how it works and how easy and comfortable it is to use.

How to Create Questionnaire

A questionnaire that asks the right questions is integral to the success of pilot testing. The Model Questionnaire in the Tools section can help you create such a form or improve your existing form. Like our Model, your questionnaire should ask:

1. Does the user have to activate the device to get it to work?

Automatic devices are generally preferable to safety features that must be activated manually.

2. Can users activate the safety device with one hand?

If a device must be activated manually, users should be able to do so quick and easily using one hand so they can keep their hands behind the needle at all times.

3. Is there a visible indicator that the safety device is on?

There should be something like a color change indicating that the device has been activated.

4. Does the user have to attach the device to an existing product?

The device should be an intrinsic part of the product, not something that has to be attached. That's because users may attach the device improperly or fail to attach it, deliberately or out of carelessness.

5. Is it possible to use the device improperly?

The safest devices are the ones that don't work unless they're used properly.

6. Is it possible to use the product without activating the safety device?

This is important because users may forget or not bother to activate the safety device.

7. Is it possible to remove or disable the safety device?

Hopefully, the answer is no.

8. Does the safety device take more time to use than current methods?

If so, workers may resist using the device or tinker with it to make it faster.

9. Is the safety device easy to use when wearing gloves?

If it isn't easy to manipulate with gloves, users may not use it or use it only after removing their gloves.

10. Does the safety device work with all size needles you currently work with?

This is a key question because needle size can have a big impact on the performance of a safety device.

11. Did the safety device work each time it was used?

A lot of devices work okay the first time but don't stand up to repeated use.

12. Is the contaminated needle covered after use and before disposal?

There should be a physical barrier, like a shield or retractable base, between the user and the used needle. That barrier should stay in place after disposal to protect workers who handle disposed sharps.

13. Is the safety device harder to dispose of than devices you currently use?

Devices that can be disposed of using your existing sharps collection system are generally preferable to those that require special containers and procedures.

14. Will use of the device require extensive training?

This can be a major barrier to implementation and use.

15. Is the device safer and more comfortable for patients than what you use now?

Hopefully, yes.

16. Is the device generally safer than what it would replace?

Ask workers to tell you what they think of the device and how it compares to what they currently use.

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